Jackson v. Commissioner
United States Tax Court
1. Petitioners and their partnership acquired territorial sublicenses to distribute specially designed tape recorders from petitioners' wholly owned corporate licensee. Petitioners and the partnership obligated themselves to contribute to an advertising cooperative with other sublicensees. The purchase price of the sublicenses and the advertising cooperative obligation were paid primarily with recourse and nonrecourse notes.
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1. Petitioners and their partnership acquired territorial sublicenses to distribute specially designed tape recorders from petitioners' wholly owned corporate licensee. Petitioners and the partnership obligated themselves to contribute to an advertising cooperative with other sublicensees. The purchase price of the sublicenses and the advertising cooperative obligation were paid primarily with recourse and nonrecourse notes. The Commissioner disallowed the deductions for amortization and advertising expense because petitioners and the partnership were not in the trade or business of…
1Opinion of the Court
GOFFE, Judge:
The Commissioner determined deficiencies in, and additions to, petitioners’ Federal income tax as follows:
Taxable _Additions to tax_ Petitioners year Deficiency Sec. 6651(a)2 Sec. 6653(a)
John L. and 1978 $18,879.05
Yvonne Jackson 1979 38,910.28 — $1,945.51
1980 74,804.85 --- 3,740.24
Gregory M. and 1978 50,906.70 $7,096.00 2,545.34
Timsey Barrow 1979 29,889.90 7,422.48 1,494.50
1980 57,518.00 14,379.50 2,875.90
1981 3,350.00 837.50 167.50
The Commissioner also asserted in his answer to this action that petitioners John L. and Yvonne Jackson failed to report income on their return for…
2Cases cited37 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Crane v. CommissionerSupreme Court of the United States · 1947
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
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3Cited by114 opinions
- John Jackson, Yvonne Jackson, Gregory M. Barrow and Timsey Barrow, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Tenth Circuit · 1989
- Levy v. CommissionerUnited States Tax Court · 1988
- Larsen v. CommissionerUnited States Tax Court · 1987
- Schwalbach v. CommissionerUnited States Tax Court · 1998
- Bussing v. CommissionerUnited States Tax Court · 1987
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